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ANSWER OF EMI MUSIC
INC. TO PETITION TO
ENFORCE CIVIL
INVESTIGATIVE DEMANDS

Respondent EMI MUSIC INC. (sued herein as EMI
Music), by its undersigned attorneys, as and for its
Answer to the Petition of the United States of America to
Enforce Civil Investigative Demand ("CID") No. 11115,
avers as follows:

1. Admits the allegations contained in
paragraph 1 of the Petition, except denies that the
Petitioner is entitled to the relief sought or any other
relief whatsoever.

2. Admits the allegations contained in
paragraph 2 of the Petition.

3. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 3 of the Petition.

4. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 4 of the Petition.

5. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 5 of the Petition.

6. Denies each and every allegation contained
in paragraph 6 of the Petition, except admits that EMI
MUSIC INC. has a place of business at 152 West 57th
Street, New York, New York 10019.

7. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 7 of the Petition.

8. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 8 of the Petition.

9. Admits the allegations contained in
paragraph 9 of the Petition, except denies that there is
a basis at law for the investigation.

10. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 10 of the Petition, except admits
that EMI MUSIC INC. received a CID which stated that it
was issued on July 7, 1994 and was returnable on
August 15, 1994.

11. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 11 of the Petition.

12. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 12 of the Petition.

13. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 13 of the Petition.

14. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 14 of the Petition.

15. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 15 of the Petition.

16. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 16 of the Petition.

17. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 17 of the Petition.

18. Admits the allegations contained in
paragraph 18 of the Petition.

19. Admits the allegations contained in
paragraph 19 of the Petition, and avers that EMI MUSIC
INC. has raised several proper objections to CID No.
11115, including, but not limited to, the objections set
forth in paragraph 19 of the Petition.

20. Admits the allegations contained in
paragraph 20 of the Petition.

21. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 21 of the Petition.

22. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 22 of the Petition.

23. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 23 of the Petition.

24. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 24 of the Petition.

25. Denies knowledge or information sufficient
to form a belief as to the truth of the allegations
contained in paragraph 25 of the Petition, except admits
that the Petition, as to EMI MUSIC INC., purports to
encompass the U.S.-located documents described in
paragraph 25 of the Petition.

26. Denies each and every allegation contained
in paragraph 26 of the Petition.

27. Denies each and every allegation contained
in paragraph 27 of the Petition, except admits that EMI
MUSIC INC. voluntarily has produced documents and
information relating to both foreign and domestic
activities while maintaining its objections to portions
of CID No. 11115, and denies knowledge or information
sufficient to form a belief as to the truth of the
allegations with respect to Respondents other than EMI
MUSIC INC.

28. Denies each and every allegation contained
in paragraph 28 of the Petition.

29. Denies each and every allegation contained
in paragraph 29 of the Petition.

AS AND FOR A FIRST AFFIRMATIVE DEFENSE

30. Under the Foreign Trade Antitrust
Improvements Act, 15 U.S.C. § 6a, the foreign business
activities that the Petitioner seeks to investigate are
outside the jurisdiction of the United States. The
Petitioner, therefore, has no jurisdiction to investigate
the matters set forth in the Petition.

AS AND FOR A SECOND AFFIRMATIVE DEFENSE

31. The Petition must be dismissed because the
Petitioner's attempt to investigate the foreign business
activities covered by the Petition violates principles of
international comity.

AS AND FOR A THIRD AFFIRMATIVE DEFENSE

32. The Court lacks personal jurisdiction over
EMI MUSIC INC., and venue is not proper under 15 U.S.C.
§ 1314(a) because EMI MUSIC INC. does not transact
business and is not found in the District of Columbia.

WHEREFORE, Respondent EMI MUSIC INC.
respectfully requests that this Court enter a judgment:

1. dismissing the Petition with prejudice;
and

2. granting EMI MUSIC INC. such other and
further relief as the Court deems just and proper.